Correspondence from Jack Spence to R. James Naegle, February 1, 1991

February 1, 1991
Mr. R. James Naegle
Engineer for Location and Environmental Studies, UDOT
4501 South 2700 West
Salt Lake City, Utah
Dear Mr. Naegle:
I am submitting the following comments on the DEIS for the Logan Canyon Highway Project. I lived in Logan for 31 years, and have recently retired from my position as Professor of Chemistry and Biochemistry, Utah State University. During this time, I have hiked, backpacked, mountain biked, and cross-country skied ex­tensively in Logan Canyon and its environs. I have been involved for many years in efforts to protect the canyon from development and from destruction of its superb scenic and wildlife values. I was one of several citizens who were responsible for the successful challenge to proposed highway improvements that resulted in the requirement that an EIS be prepared for the project in 1979. Since then, I have been intimately involved in both planning efforts for the project, and in opposition to the project by several environmental organizations. I served as the represen­tative of the environmental community on the ID team which met regularly to provide input to UDOT and CH2M Hill during the per­iod from June, 1986 - July, 1987. I attended almost all of the meetings during this period and made contributions to all the technical memoranda prepared for the project. I believe I am well aware of all the problems associated with the project and with the potential impacts on the values of Logan Canyon.
General Comments:
1. The purpose of the project is " ... to improve traffic flow and to increase traffic carrying capacity of the road" [1-8]. to achieve these goals in a substantial manner, however, would clear­ly require the construction of a high speed highway through the entire canyon [the standard design speed for a minor arterial road is 50 mph]. This has been rejected because " ... the curve straightening required to achieve this design speed would have required extreme changes to the terrain that would have greatly altered the canyon's environment" [2-9J. Table 4-3 indicates that even with the standard Arterial Alternative driv­ing time for the entire canyon would decrease only 5-9 minutes, and traffic carrying capacity would increase only about 33%, while at the same time resulting in serious and substantial effects on the scenic, wildlife, botanical and aquatic resources of the canyon, particularly the middle section [Ch. 4]. It seems clear that even the most ambitious alternative will provide only minimal improvement in traffic flow and carrying capacity, and at great cost to the environment of the canyon. Therefore, the question must be asked: why do it? Bridge replacement, resurfacing, and signing and a few minor changes as described in the Conservationsts Alternative would acheive almost the same result, with minimal cost and distrurbance to the canyon.
2. According to the Regulations for Implementing the National Environmental Policy Act, the EIS must: [a] "Rigorously explore ... all reasonable alternatives ..." and [b] "include reasonable alternatives not within the jurisdiction of the lead agency" [§1502.14]. The DEIS does not include a reasonable alternative which was discussed in the 10 team meetings: designation of Idaho state Highway 34, from Preston, Idaho to Freedom, Wyoming as Alternative U.S. Highway 91 or 89. Since the major traffic problem with the Logan Canyon Highway occurs only in the Summer months, primarily on weekends or national holidays, with 80% of the traffic passing entirely through the canyon, and with a large proportion continuing on to Jackson, Grand Teton and Yellowstone, the designation of a U.S. highway through Preston, Soda Springs, Wayan and Freedom to join US 89 in Star Valley would provide an ideal route for this traffic and solve, in large mea­sure, the traffic problems in Logan Canyon. This route already has an excellent highway from Logan to Soda Springs, and from Wayan to Freedom. Some improvement in the section from Soda Springs to Wayan might be needed, but this is only slightly longer than the proposed project in the canyon. Most importantly, there are no major passes to climb and no narrow, environmentally sensitive canyons to traverse. In fact, for the most people in Logan who travel to Grand Teton and Yellowstone in the Summer, this is already the route of choice. By redesignating the route, providing
proper signing and, perhaps, with some improvement in the Soda Springs to Wayan section, much of the Summer traffic through the canyon would be diverted. The DEIS is clearly deficient, since it does not discusss this reasonable and practical alternative.
3. The DEIS describes the 10 team participati .on in project plan­ing stages on p 7-2. The basic role of the 10 team was defined as follows:
"Provide input on the technical memoranda and materials developed in connection with the study. Review technical memoranda and provide insight and per­spective on issues and concerns as they relate to the study. Provide a recommendation on the class of environmental action and the alternatives developed in connection with the study."
The DEIS then proceeds as if, in fact, this role was performed by the 10 team. Only two, at most, of the many technical memoranda were properly reviewed and accepted by the 10 team, and no recom­mendation of any kind was provided to UDOT or CH2M Hill. After July of 1987, the meetings of the ID team were abruptly halted, and no reason for this was given to the members. No further meet­ings were held, and no further input was requested. It was generally felt by most members at that time that very little had been accomplished and that nothing had been agreed upon. It was concluded by the environmental representatives that UDOT did not wish to hear further of the concerns of the environmental communi­ty, and subsequent actions on their part bear this out. The DEIS should be rewritten to reflect what happened. As it now stands, it would appear that the ID team performed their role as described, which is false. While much input to the technical memoranda was provided by the team, no decisions or recommendations were made.
4. The DEIS does not contain sufficient detail to allow reason­able understanding and proper comparison of the alternatives. With the exception of the Composireand Conservationists Alter­natives, which appear in the Appendix, it is difficult to obtain from the text and the tables a clear picture of just what the other alternatives entail. The maps are not of large enough scale to provide a good understanding of what the various construction sites, curve flattenings, etc., will do to the visual qualities of the canyon. CEQ regulations for describing the alternatives state " ... it [EIS] should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharp­ly defining the issues and providing a clear basis for choice amoung options by the decision maker and the public." Further, the DEIS will "Rigorously explore and objectively evaluate all reason­able alternatives ... " and "Devote substantial treatment to each alternative considered in detail ... so that reviewers may evaluate their comparative merits" [§lS02.14J. Clearly, only the Composite Alternative and the Conservationists Alternative [described in considerable detail in the Appendix] meet the NEPA requirements.
5. In several places, especially in Environmental Consequences and Mitigation [Ch. 4], reference is made to "final design plans" when discussing consequences or mitigation. As an example, "Dur­ing the final design, a wetlands mitigation plan would be developed that would specify areas to be developed for replacement, grading to be undertaken, kind and number of plants to be planted, and maintenance provisions" [4-32]. In other words, mitigation plans [and in some cases, environmental impacts] will be discussed in some later plan, currently not available to the public. This is a clear and egregious violation of NEPA requirements, which stip­ulate that the EIS must provide all information necessary for concerned citizens to evaluate the effects of the proposed actions and mitigation procedures. It is completely unacceptable to refer to possible future plans, not described in the EIS, to obtain the necessary information on which informed decisions may be made. The DEIS must be revised to include all such plans [both in the example cited, and in the other places where some nebulous future "final design" plan is referred to].
6. The DEIS states [2-38J that the Composite Alternative" ... is not at this time a preferred alternative." This is patently false. As discussed above, only this alternative and the Conservationists Alternative are described in detail [Appendix]. Since it is highly unlikely UDOT, FHWA and CH2M Hill would, under any circumstances, endorse the Conservationists Alternative, the preferntial treat­ment given the Composite Alternative in the DEIS clearly mandates its choice as the Preferred Alternative. More importantly, how­ever, this preferential treatment of this alternative is in viola­tion of the regulations governing the preparation of an EIS, as discussed above, since these regulations require the DEIS to "Rigorously explore and objectively evaluate all reasonable alter­natives ... ". Equal and objective treatment for all alternatives is required, regardless of whether or not a "Preferred Alternative" has been designated. Finally, §lS02.2[g] of the Regulations states, "Environmental Impact Statements shall serve as the means of assessing the environmental impact of proposed agency actions, rather than justifying decisions already made."
7. A major problem with the DEIS is that it gives no indication of what is to be done with the large amount of fill that will be removed in all the alternatives except No Action and Conservation­ists. Fill was simply disposed of along the highway during the construction in the lower canyon, creating unsightly and environmentally damaging situations. These deposits are still easily seen in many places, and indicate the magnitude of this problem. The only reference I have found in the DEIS is in the Composite Alternative [Appendix A, p.6] where it states: "Excavated material will be disposed of in acceptable manner." Again, this is in violation of the CEQ regulations for an EIS, since no indication
is given as what this "acceptable" manner involves. The amount of fill that must be disposed of should be calcuable by the UDOT or CH2M Hill engineers, and a plan for its disposal should have been included in DEIS for each alternative. To say merely that it will be disposed of in an "acceptable manner" is clearly insufficient. Acceptable to whom? UDOT, CH2M Hill, the Forest Service, conserva­tionists? It is quite likely the disposal of fill will increase considerably the number of violations of the Forest Service visual quality ratings in the canyon, and may impact seriously the stream maintenance directives. A plan for fill disposal, sufficiently detailed to allow citizens to evaluate its effects, must be includ­ed in the EIS.
8. In several places in the DEIS, reference is made to improved conditions for bicycling and pedestrians, particularly in those alternatives involving road widening. The issue of bicycles and pedestrian traffic in the middle and upper parts of the canyon is a straw man, since there is very little such use. Because of the distance from Logan to the beginning of the project [approximately 10 miles], most cycling and pedestrian traffic [jogging, e.g.] occurs in the lower canyon. About the only time many cyclists are found above Right Fork is during the infrequent cross-country races. Therefore, to use this issue to justify the construction proposed in most of the alteratives is unjustified.
9. The issue of replacement of wetlands destroyed by construction for many of the alternatives is not properly addressed. The amount of such lands lost is substantial [see Table 4-15], and these must be replaced in kind. Little discussion of this problem is found in the DEIS. On p. 4-54, it is stated the "Forest Service would be concerned with relocation of wetlands out of the canyon." On p. 4-32, however, the DEIS states that only about 6 acres of re­placement [out of approximately 20-30 acres, depending on the alternative] could be found in the project area. The remaining would have to be found in the lower canyon [how many? where?] or, most likely, out of the canyon. Since these wetlands are the most important habitat for wildlife in the canyon, their loss is extreme­ly serious. But, as discussed in comment [5] above, no plan for their acceptable replacement is found in the DEIS, but will be presented later in the "final design plan." Again, as discussed above, this is a violation of the CEQ regulations, and is complete­ly unacceptable.
10. The DEIS states [p. 4-1]: "Since no past or future projects, have been identified, no cumulative effects are expected." This is disingenuous indeed. With the Composite Alternative, which is clearly favored, only approximately 4 miles of the middle canyon will remain "unimproved" [up to the standard arterial design]. Does anyone believe that UDOT will leave this section alone in the future? The presence of a 4 mile section of 25 mph design speed highway , in between 50-60 mph design speed sections above and below will be a bottleneck for traffic on those congested summer holidays, and there will be enormous pressure to "complete the job." There­fore, this real possibility shouldbe discussed in this alternative and its effects considered as cumulative. If it should occur, it would be equivalent to having the Standard Arterial Standard adopt­ed. Anyone who has dealt with UDOT over the last few years in the Logan Canyon cannot be sanquine about the assurance that "no past
or future projects have been identified .... "
Specific Comments:
1 [1-19]. Traffic Projections. This is a most important section, since the rationale for construction is based primarily on future traffic growth projections in the canyon. The DEIS states that traffic projections were made by linear approximation of past trends [low, 1.67% increase yearly] and linear approximation as a function of northern Utah population growth [high, 2.33% increase yearly]. These projections are made with a least squares regression analysis of past data and a projection of the regression line to the year 2010. The precision of such projections is critical, and this depends on the fit of the line to the linear regression equation. This can be estimated by the correlation coefficient, r2. Using
the data provided by Fig. 1-4, the Annual ADT least squares line has an r2 of 0.154, with an annual growth of 0.47%. This is a very poor correlation, and indicates little, if any, relationship exists bet ween the variables [ADT and year]. It also means any predic­tions are essentially without value. The Summer ADT least squares line has an r2 of 0. 812, with an annual growth of 2.15%. While this is quite acceptable, it clearly does not give 1.67%, as report­ed in the text. What data were used to obtain the 1 .67% growth, and what is the correlation coefficient for this regression? The NEPA requirements indicate such data must be provided in the EIS in order to determine if the projection has any value. Furthermore, no data is provided concering the high projection [2.15%] from traffic volume as a function of population growth. Where is this
data? How can its usefullness be evaluated without presenting it? What is the correlation coefficient for its regression line? As indicated above, there is a serious question about the use of the annual ADT data, since the correlation is essentially non­existent. Is it true of the data used for the Summer ADT and for the population growth/traffic volume data? Finally, numbers such as 1.67% or 2.33% are meaningless without some indication of the errors associated with them. If the errors are small [5-10%] the estimates are useful; if they are higher than 50%, they are useless. These error estimates are easily obtained from the data by calcula­tion of the standard deviation of measurement, or the standard
deviation of the slope [growth rate]. These should be included, along with all the data, in order that a proper evaluation of the precision of the traffic projections may be made. As it now stands, the DEIS is grossly deficient in this regard.
2 [1-22]. Safety . The DEIS states that safety is "... not a primary reason for this project". In fact, there is no evidence presented in the DEIS that the Logan Canyon highway is unsafe in any place. Safety is a relative term, and can only be evaluated with respect to other highways. Early in the ID Team meetings, data was requested from UDOT concerning accidents/ADT/mile in the canyon, as well as similar data for other Utah highways, particularly mountain routes, so that a statistical comparison could be made. Such data was never provided. In lieu of this, I suggested a comparison of 0.1 mile sections of the canyon might be made to determine if any areas were more accident prone than others. This was done, and that appears in Table 1-5. The statistical analysis compares the average number of accidents per year per 0.1 mile against the number to be expect­ed if the distribution were random, at an 80% confidence level. The results are not surprising, since a similar analysis would give similar results for any highway. Furthermore, the methodology has some serious faults: since the ADT varies considerably for various sections of the canyon, this should be taken into account, which I do not think was done; instead of simply calculating an average and
using a t-test, a better measure for randomness would have been a chi-square test. In any case, the results, at best, identify those sections where a higher than average number of accidents have occurred. They do not show that these sections are unsafe: that would require a comparison with data from other mountain highways, which was not done. In addition, no indication of the severity of the accidents is given. Mortalities, and data concerning severity of injuries, is available from the Highway Patrol. This data shows that while the number of accidents in the middle section of the canyon, e.g., is higher than in the lower [improved] section, the majority of the fatalities have occurred in the lower section, pri­marily as a result of the higher speeds. While most of the accidents in the middle section involve some property damage, mainly as a result of going off the road in Winter, it appears to be much safer with respect to serious injury or death than the improved [lower]
section, although it must be pointed out that no statistical analy­sis of this has been done either. Finally, the data only cover the period from 1980-85. The results would be more reliable and useful if the data from 1986-90 were included particularly since improved signing and highway marking were instituted in 1987-88. At the very least, it can be said without reservation that the data in the DEIS provide no basis what soever for concluding that any section of the canyon is unsafe. The DEIS also states that "a number of the proposed improvements would improve safety conditions on the highway . What is the basis for this assertion? No evidence is presented and no details given as to how a given "improvement" would, in fact, improve safety. This is , in fact, a non-sequitur, since no evidence is presented that the highway is unsafe. While a proper statistical analysis, using allavailable data might have shown some safety problems in the canyon, this was not done, and a
conculsion supporting the presence of a safety problem cannot be drawn in its absence.
3 [2-21]. Spot Improvements Alternative. According to the Table 2-2, there are 61 "potential" spot improvements to the highway in this alternative. These vary enormously in their impact to the canyon. No indication, however, is given as to which spot improve­ments will be undertaken. Instead, a "shopping list" is provided, leaving the selection for some future date by UDOT. Thus, it is clearly impossible to evaluate the effects of this alternative. Such a "shopping list" is equally clearly a violation of the CEQ Regulations, as discussed above, which require that the effects of all alternatives must be fully discussed, so that informed choices may be made. As a result, this alternative must be dropped from the EIS, since it is in violation of the NEPA regulations.
4. [2-21]. Conservationists Alternative. The DEIS states that this alternative " ... would maintain only the present traffic volume capacity of the road ... " This is false. The Conservationists Alternative includes widening of the bridges, the addition of several paved turnouts for slow traffic, and the addition of three climbing lanes, all clearly designed to facilitate traffic flow during peak periods. Since many of these improvements are included in UDOT alternatives, which are presumably designed to improve traffic flow, it is difficult to understand how they will not make
some contribution in the Conservationists Alternative. This is evidence of bias in the DEIS against this alternative, and it should be deleted.
5. [3-l]. The DEIS states that "Cache County is expected to have considerable growth, with population almost doubling by the year 2010 ... " What is the basis for this statement? No data on expect­ed population growth, or past trends, is presented in sufficient detail for analysis in the DEIS. Earlier growth predictions have been modified considerably in light of more recent data, generally lowering such predictions. Clearly, the intent of this statement is to support the traffic predictions of chapter 1. Without data, however, this statement is unsupported, and may be quite in error. CEQ Regulations require that data in support of predictions must be made available in the DEIS.
6. [3-16]. Population and Growth. Table 3-2 gives minimal data on past population in Cache and Rich counties. It also projects the estimated future population growth to the year 2010. No data is given in support of this table. What is the date of the data? Which entries are actual population figures, and which projections? In order to determine the validity of the predictions, past data for the years 1970-1990 must be given, as well as a description of the regression methodolgy used to make the projections. Without this, it is impossible to know if these numbers are valid. This problem has been discussed above with respect to predictions of traffic volume and the same caveats apply.
7. [4-4]. Benefit/Cost. The DEIS states that "Table 4-2 does not include values of environmental impacts or benefits." The cost-­benefit analysis therefore is completely invalid, since the major controversy with the project is its effects on the environment. Why are such costs, to the extent they can be estimated, not includ­ed? Such costs should include tourist doll ars spent because of the scenic attractions of Logan Canyon, dollars spent by fishermen, hikers, bikers and skiers to enjoy the values of the canyon, and dollars associated with water quality and wildlife habitat. To what extent will each of t hese be affected by each alternative? this is a critical part of any cost-benefit analysis, but it is totally ignored in the DEIS. As a result, this analysis is without value, and should be completely revised to take into account these impor­tant factors. Again, CEQ Regulations require that all relevant factors be considered in evaluation of environmental effects.
8. [4-26]. Botanical and Wildlife Resources. Botanical impacts. The DEIS indicates that the Standard Arterial Alternative, Rich County Alignment Alternatives, and the Modified Standard Alternative may constitute a significant threat to the endangered species Primula maguirei. In fact, a conflict of expert opinion exists on this effect, and, if it is indeed significant, these alternatives would have to be dropped, or modified. Thus, it is impossible to determine from the DEIS if these alternatives must be further considered. This constitutes a violation of the CEQ Regulations
referred to above, since all environmental effects must be specified and discussed for each alternative. This conflict should have been resolved before the DEIS was published, and it must be resolved before the EIS is completed if any of these alternatives are to be considered. Table 4-15 is in error for these alternatives, since it indicates there are no Threatened or Endangered Species in any alternative.
9. [4-36]. Conservationists Alternative. The DEIS states that impacts [on wildlife] " ... would be similar to the Spot Improvements Alternative, but would be less extensive." This is grossly mislead­ing, as a comparison of the maps for the Middle Canyon for the two alternatives, and Tables 2-2 and 2-3 shows. The impacts of the Conservationists Alternative are far less than those of the Spot Alternative. This statement is further evidence of the bias of the DEIS against the Conservationists Alternative.
10. [4-42). Mitigation. Both tables 4-9 and 4-10 indicate that the VQR of the Composite and Conservationists Alternatives, with and without mitigation, are almost identical. This is indeed difficult to believe, considering the great difference in the amount of land disturbed in the two alternatives [see maps and tables for each]. A justification of this conclusion, in quantitative terms must be furnished; otherwise, it stretches the credulity of any rational person.
11. [4-53). Land Use. Compliance with Local Land Use Plans, Wasatch-Cache National Forest and Resources Management Plan-Manage­ment
Directives for Logan Canyon. The DEIS indicates that in all alternatives, except No Action, the visual management directives of the Forest Plan would be violated, and in all Alternatives, except No Action and Conservationists Alternatives, maintenance of stream habitat directives would be violated. The Conservationists Alternative fails to comply with the visual VQR of retention in only one, relatively minor, instance, while the other alternatives fail in this respect in varying degrees, with the Standard Arterial be­ing the most egregious. In fact, this alternative would not comply for the majority of the Middle Canyon, and much of the Upper ranyon [Beaver Creek, e.g.). The Composite Alternative fails, also to meet the standard, particularly in the Middle Canyon and in the Beaver Creek area. The OEIS assumes that, with the adoption of any of these non-complying alternatives, the Forest Plan will be amended , changing the VQR rating from retention to modification, or partial retention, and dropping the stream habitat maintenance requirement in affected areas. In reading the OEIS, one gets the impression that these changes would be relatively simple, and would be almost automatic. Such is far from the case. The Forest Plan was developed only after many years of work by the Forest Service and was subjected to extensive and critical public review. It should be pointed out that the Forest Plan is one of the few Forest plans in Utah, or in the nation, that was not appealed by environ­mental organizations. The reason for this is that this plan was
viewed as being perhaps the best in the state, and this judgement was based, in part, on the protection it provided for Logan Canyon. The VQR ratings of retention and the stream habitat maintenance requirements are a critical part of this protection, and they will not be changed without a long process of appeal and possible legal action. The Forest Plan states "The road will not be raised to a higher standard than existing." Environmental organizations and­conservationists regard this as binding on the Forest Service, and only compelling reasons, certainly of far more importance than any cited in the DEIS, would be required to change this. In fact, any significant change for purposes of raising the road to a "higher standard" will be considered as a profound breach of faith by the Forest Service that will certainly greatly reduce its credibility. Furthermore, the large number of areas requiring changes in the VQR, and the destruction of riparian zones [stream maintenance] in all alternatives except the Concervationists and No Action, will require not an amendment [or amendments] - but rather a Plan Revision, a
far more lengthy and difficult process than an amendment. The DEIS treats this matter far too lightly, and does not discuss what the process of amendment or revision entails. Much time and resources will be e xpended, both by the Forest Service and environmental organizations, in order to change [or prevent change] of the Plan to meet any of the Alternatives except No Action or the Conservation­ists.
In Summary, the DEIS provides insufficient justification for con­struction, lacks necessary detail, is biased towards the Composite Alternative, puts off required discussion of effects and mitigation to a future "final design plan" in violation of CEQ REgulations and does not provide the basis for a rational decision concerning alternatives. Considering the cost [approximately $l,000,000], the great amount of time spent by everyone, and the fact that most of the serious problems discussed here were discussed repeatedly at the ID Team meetings, the DEIS is, to put it charitably, a disappointment. More importantly, it does not meet the primary criterion of an EIS, which is defined in the CEQ regulations governing the preparation of environmental impact statements: "It shall provide full and fair discussion of significant environmental im­pacts
and shall inform the decision-makers and the public of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of the human environment." [§1502.1J.
Finally, as provided for in the CEQ Regulations [§1503.3] [a]], I wish to express my opinion of the merits of the alternatives. Only the Conservationists Alternative meets the needs of the canyon: reconstruction of the bridges, and some improvement in traffic flow by the use of pullouts and passing lanes in acceptable loca­tions, and the maintenance of highway which fits into Logan Canyon with minimal ecological disturbance and maximum safety. I strongly endorse this alternative.
Jack T. Spence

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February 1, 1991
Mr. R. James Naegle
Engineer for Location and Environmental Studies, UDOT
4501 South 2700 West
Salt Lake City, Utah
Dear Mr. Naegle:
I am submitting the following comments on the DEIS for the Logan Canyon Highway Project. I lived in Logan for 31 years, and have recently retired from my position as Professor of Chemistry and Biochemistry, Utah State University. During this time, I have hiked, backpacked, mountain biked, and cross-country skied ex­tensively in Logan Canyon and its environs. I have been involved for many years in efforts to protect the canyon from development and from destruction of its superb scenic and wildlife values. I was one of several citizens who were responsible for the successful challenge to proposed highway improvements that resulted in the requirement that an EIS be prepared for the project in 1979. Since then, I have been intimately involved in both planning efforts for the project, and in opposition to the project by several environmental organizations. I served as the represen­tative of the environmental community on the ID team which met regularly to provide input to UDOT and CH2M Hill during the per­iod from June, 1986 - July, 1987. I attended almost all of the meetings during this period and made contributions to all the technical memoranda prepared for the project. I believe I am well aware of all the problems associated with the project and with the potential impacts on the values of Logan Canyon.
General Comments:
1. The purpose of the project is " ... to improve traffic flow and to increase traffic carrying capacity of the road" [1-8]. to achieve these goals in a substantial manner, however, would clear­ly require the construction of a high speed highway through the entire canyon [the standard design speed for a minor arterial road is 50 mph]. This has been rejected because " ... the curve straightening required to achieve this design speed would have required extreme changes to the terrain that would have greatly altered the canyon's environment" [2-9J. Table 4-3 indicates that even with the standard Arterial Alternative driv­ing time for the entire canyon would decrease only 5-9 minutes, and traffic carrying capacity would increase only about 33%, while at the same time resulting in serious and substantial effects on the scenic, wildlife, botanical and aquatic resources of the canyon, particularly the middle section [Ch. 4]. It seems clear that even the most ambitious alternative will provide only minimal improvement in traffic flow and carrying capacity, and at great cost to the environment of the canyon. Therefore, the question must be asked: why do it? Bridge replacement, resurfacing, and signing and a few minor changes as described in the Conservationsts Alternative would acheive almost the same result, with minimal cost and distrurbance to the canyon.
2. According to the Regulations for Implementing the National Environmental Policy Act, the EIS must: [a] "Rigorously explore ... all reasonable alternatives ..." and [b] "include reasonable alternatives not within the jurisdiction of the lead agency" [§1502.14]. The DEIS does not include a reasonable alternative which was discussed in the 10 team meetings: designation of Idaho state Highway 34, from Preston, Idaho to Freedom, Wyoming as Alternative U.S. Highway 91 or 89. Since the major traffic problem with the Logan Canyon Highway occurs only in the Summer months, primarily on weekends or national holidays, with 80% of the traffic passing entirely through the canyon, and with a large proportion continuing on to Jackson, Grand Teton and Yellowstone, the designation of a U.S. highway through Preston, Soda Springs, Wayan and Freedom to join US 89 in Star Valley would provide an ideal route for this traffic and solve, in large mea­sure, the traffic problems in Logan Canyon. This route already has an excellent highway from Logan to Soda Springs, and from Wayan to Freedom. Some improvement in the section from Soda Springs to Wayan might be needed, but this is only slightly longer than the proposed project in the canyon. Most importantly, there are no major passes to climb and no narrow, environmentally sensitive canyons to traverse. In fact, for the most people in Logan who travel to Grand Teton and Yellowstone in the Summer, this is already the route of choice. By redesignating the route, providing
proper signing and, perhaps, with some improvement in the Soda Springs to Wayan section, much of the Summer traffic through the canyon would be diverted. The DEIS is clearly deficient, since it does not discusss this reasonable and practical alternative.
3. The DEIS describes the 10 team participati .on in project plan­ing stages on p 7-2. The basic role of the 10 team was defined as follows:
"Provide input on the technical memoranda and materials developed in connection with the study. Review technical memoranda and provide insight and per­spective on issues and concerns as they relate to the study. Provide a recommendation on the class of environmental action and the alternatives developed in connection with the study."
The DEIS then proceeds as if, in fact, this role was performed by the 10 team. Only two, at most, of the many technical memoranda were properly reviewed and accepted by the 10 team, and no recom­mendation of any kind was provided to UDOT or CH2M Hill. After July of 1987, the meetings of the ID team were abruptly halted, and no reason for this was given to the members. No further meet­ings were held, and no further input was requested. It was generally felt by most members at that time that very little had been accomplished and that nothing had been agreed upon. It was concluded by the environmental representatives that UDOT did not wish to hear further of the concerns of the environmental communi­ty, and subsequent actions on their part bear this out. The DEIS should be rewritten to reflect what happened. As it now stands, it would appear that the ID team performed their role as described, which is false. While much input to the technical memoranda was provided by the team, no decisions or recommendations were made.
4. The DEIS does not contain sufficient detail to allow reason­able understanding and proper comparison of the alternatives. With the exception of the Composireand Conservationists Alter­natives, which appear in the Appendix, it is difficult to obtain from the text and the tables a clear picture of just what the other alternatives entail. The maps are not of large enough scale to provide a good understanding of what the various construction sites, curve flattenings, etc., will do to the visual qualities of the canyon. CEQ regulations for describing the alternatives state " ... it [EIS] should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharp­ly defining the issues and providing a clear basis for choice amoung options by the decision maker and the public." Further, the DEIS will "Rigorously explore and objectively evaluate all reason­able alternatives ... " and "Devote substantial treatment to each alternative considered in detail ... so that reviewers may evaluate their comparative merits" [§lS02.14J. Clearly, only the Composite Alternative and the Conservationists Alternative [described in considerable detail in the Appendix] meet the NEPA requirements.
5. In several places, especially in Environmental Consequences and Mitigation [Ch. 4], reference is made to "final design plans" when discussing consequences or mitigation. As an example, "Dur­ing the final design, a wetlands mitigation plan would be developed that would specify areas to be developed for replacement, grading to be undertaken, kind and number of plants to be planted, and maintenance provisions" [4-32]. In other words, mitigation plans [and in some cases, environmental impacts] will be discussed in some later plan, currently not available to the public. This is a clear and egregious violation of NEPA requirements, which stip­ulate that the EIS must provide all information necessary for concerned citizens to evaluate the effects of the proposed actions and mitigation procedures. It is completely unacceptable to refer to possible future plans, not described in the EIS, to obtain the necessary information on which informed decisions may be made. The DEIS must be revised to include all such plans [both in the example cited, and in the other places where some nebulous future "final design" plan is referred to].
6. The DEIS states [2-38J that the Composite Alternative" ... is not at this time a preferred alternative." This is patently false. As discussed above, only this alternative and the Conservationists Alternative are described in detail [Appendix]. Since it is highly unlikely UDOT, FHWA and CH2M Hill would, under any circumstances, endorse the Conservationists Alternative, the preferntial treat­ment given the Composite Alternative in the DEIS clearly mandates its choice as the Preferred Alternative. More importantly, how­ever, this preferential treatment of this alternative is in viola­tion of the regulations governing the preparation of an EIS, as discussed above, since these regulations require the DEIS to "Rigorously explore and objectively evaluate all reasonable alter­natives ... ". Equal and objective treatment for all alternatives is required, regardless of whether or not a "Preferred Alternative" has been designated. Finally, §lS02.2[g] of the Regulations states, "Environmental Impact Statements shall serve as the means of assessing the environmental impact of proposed agency actions, rather than justifying decisions already made."
7. A major problem with the DEIS is that it gives no indication of what is to be done with the large amount of fill that will be removed in all the alternatives except No Action and Conservation­ists. Fill was simply disposed of along the highway during the construction in the lower canyon, creating unsightly and environmentally damaging situations. These deposits are still easily seen in many places, and indicate the magnitude of this problem. The only reference I have found in the DEIS is in the Composite Alternative [Appendix A, p.6] where it states: "Excavated material will be disposed of in acceptable manner." Again, this is in violation of the CEQ regulations for an EIS, since no indication
is given as what this "acceptable" manner involves. The amount of fill that must be disposed of should be calcuable by the UDOT or CH2M Hill engineers, and a plan for its disposal should have been included in DEIS for each alternative. To say merely that it will be disposed of in an "acceptable manner" is clearly insufficient. Acceptable to whom? UDOT, CH2M Hill, the Forest Service, conserva­tionists? It is quite likely the disposal of fill will increase considerably the number of violations of the Forest Service visual quality ratings in the canyon, and may impact seriously the stream maintenance directives. A plan for fill disposal, sufficiently detailed to allow citizens to evaluate its effects, must be includ­ed in the EIS.
8. In several places in the DEIS, reference is made to improved conditions for bicycling and pedestrians, particularly in those alternatives involving road widening. The issue of bicycles and pedestrian traffic in the middle and upper parts of the canyon is a straw man, since there is very little such use. Because of the distance from Logan to the beginning of the project [approximately 10 miles], most cycling and pedestrian traffic [jogging, e.g.] occurs in the lower canyon. About the only time many cyclists are found above Right Fork is during the infrequent cross-country races. Therefore, to use this issue to justify the construction proposed in most of the alteratives is unjustified.
9. The issue of replacement of wetlands destroyed by construction for many of the alternatives is not properly addressed. The amount of such lands lost is substantial [see Table 4-15], and these must be replaced in kind. Little discussion of this problem is found in the DEIS. On p. 4-54, it is stated the "Forest Service would be concerned with relocation of wetlands out of the canyon." On p. 4-32, however, the DEIS states that only about 6 acres of re­placement [out of approximately 20-30 acres, depending on the alternative] could be found in the project area. The remaining would have to be found in the lower canyon [how many? where?] or, most likely, out of the canyon. Since these wetlands are the most important habitat for wildlife in the canyon, their loss is extreme­ly serious. But, as discussed in comment [5] above, no plan for their acceptable replacement is found in the DEIS, but will be presented later in the "final design plan." Again, as discussed above, this is a violation of the CEQ regulations, and is complete­ly unacceptable.
10. The DEIS states [p. 4-1]: "Since no past or future projects, have been identified, no cumulative effects are expected." This is disingenuous indeed. With the Composite Alternative, which is clearly favored, only approximately 4 miles of the middle canyon will remain "unimproved" [up to the standard arterial design]. Does anyone believe that UDOT will leave this section alone in the future? The presence of a 4 mile section of 25 mph design speed highway , in between 50-60 mph design speed sections above and below will be a bottleneck for traffic on those congested summer holidays, and there will be enormous pressure to "complete the job." There­fore, this real possibility shouldbe discussed in this alternative and its effects considered as cumulative. If it should occur, it would be equivalent to having the Standard Arterial Standard adopt­ed. Anyone who has dealt with UDOT over the last few years in the Logan Canyon cannot be sanquine about the assurance that "no past
or future projects have been identified .... "
Specific Comments:
1 [1-19]. Traffic Projections. This is a most important section, since the rationale for construction is based primarily on future traffic growth projections in the canyon. The DEIS states that traffic projections were made by linear approximation of past trends [low, 1.67% increase yearly] and linear approximation as a function of northern Utah population growth [high, 2.33% increase yearly]. These projections are made with a least squares regression analysis of past data and a projection of the regression line to the year 2010. The precision of such projections is critical, and this depends on the fit of the line to the linear regression equation. This can be estimated by the correlation coefficient, r2. Using
the data provided by Fig. 1-4, the Annual ADT least squares line has an r2 of 0.154, with an annual growth of 0.47%. This is a very poor correlation, and indicates little, if any, relationship exists bet ween the variables [ADT and year]. It also means any predic­tions are essentially without value. The Summer ADT least squares line has an r2 of 0. 812, with an annual growth of 2.15%. While this is quite acceptable, it clearly does not give 1.67%, as report­ed in the text. What data were used to obtain the 1 .67% growth, and what is the correlation coefficient for this regression? The NEPA requirements indicate such data must be provided in the EIS in order to determine if the projection has any value. Furthermore, no data is provided concering the high projection [2.15%] from traffic volume as a function of population growth. Where is this
data? How can its usefullness be evaluated without presenting it? What is the correlation coefficient for its regression line? As indicated above, there is a serious question about the use of the annual ADT data, since the correlation is essentially non­existent. Is it true of the data used for the Summer ADT and for the population growth/traffic volume data? Finally, numbers such as 1.67% or 2.33% are meaningless without some indication of the errors associated with them. If the errors are small [5-10%] the estimates are useful; if they are higher than 50%, they are useless. These error estimates are easily obtained from the data by calcula­tion of the standard deviation of measurement, or the standard
deviation of the slope [growth rate]. These should be included, along with all the data, in order that a proper evaluation of the precision of the traffic projections may be made. As it now stands, the DEIS is grossly deficient in this regard.
2 [1-22]. Safety . The DEIS states that safety is "... not a primary reason for this project". In fact, there is no evidence presented in the DEIS that the Logan Canyon highway is unsafe in any place. Safety is a relative term, and can only be evaluated with respect to other highways. Early in the ID Team meetings, data was requested from UDOT concerning accidents/ADT/mile in the canyon, as well as similar data for other Utah highways, particularly mountain routes, so that a statistical comparison could be made. Such data was never provided. In lieu of this, I suggested a comparison of 0.1 mile sections of the canyon might be made to determine if any areas were more accident prone than others. This was done, and that appears in Table 1-5. The statistical analysis compares the average number of accidents per year per 0.1 mile against the number to be expect­ed if the distribution were random, at an 80% confidence level. The results are not surprising, since a similar analysis would give similar results for any highway. Furthermore, the methodology has some serious faults: since the ADT varies considerably for various sections of the canyon, this should be taken into account, which I do not think was done; instead of simply calculating an average and
using a t-test, a better measure for randomness would have been a chi-square test. In any case, the results, at best, identify those sections where a higher than average number of accidents have occurred. They do not show that these sections are unsafe: that would require a comparison with data from other mountain highways, which was not done. In addition, no indication of the severity of the accidents is given. Mortalities, and data concerning severity of injuries, is available from the Highway Patrol. This data shows that while the number of accidents in the middle section of the canyon, e.g., is higher than in the lower [improved] section, the majority of the fatalities have occurred in the lower section, pri­marily as a result of the higher speeds. While most of the accidents in the middle section involve some property damage, mainly as a result of going off the road in Winter, it appears to be much safer with respect to serious injury or death than the improved [lower]
section, although it must be pointed out that no statistical analy­sis of this has been done either. Finally, the data only cover the period from 1980-85. The results would be more reliable and useful if the data from 1986-90 were included particularly since improved signing and highway marking were instituted in 1987-88. At the very least, it can be said without reservation that the data in the DEIS provide no basis what soever for concluding that any section of the canyon is unsafe. The DEIS also states that "a number of the proposed improvements would improve safety conditions on the highway . What is the basis for this assertion? No evidence is presented and no details given as to how a given "improvement" would, in fact, improve safety. This is , in fact, a non-sequitur, since no evidence is presented that the highway is unsafe. While a proper statistical analysis, using allavailable data might have shown some safety problems in the canyon, this was not done, and a
conculsion supporting the presence of a safety problem cannot be drawn in its absence.
3 [2-21]. Spot Improvements Alternative. According to the Table 2-2, there are 61 "potential" spot improvements to the highway in this alternative. These vary enormously in their impact to the canyon. No indication, however, is given as to which spot improve­ments will be undertaken. Instead, a "shopping list" is provided, leaving the selection for some future date by UDOT. Thus, it is clearly impossible to evaluate the effects of this alternative. Such a "shopping list" is equally clearly a violation of the CEQ Regulations, as discussed above, which require that the effects of all alternatives must be fully discussed, so that informed choices may be made. As a result, this alternative must be dropped from the EIS, since it is in violation of the NEPA regulations.
4. [2-21]. Conservationists Alternative. The DEIS states that this alternative " ... would maintain only the present traffic volume capacity of the road ... " This is false. The Conservationists Alternative includes widening of the bridges, the addition of several paved turnouts for slow traffic, and the addition of three climbing lanes, all clearly designed to facilitate traffic flow during peak periods. Since many of these improvements are included in UDOT alternatives, which are presumably designed to improve traffic flow, it is difficult to understand how they will not make
some contribution in the Conservationists Alternative. This is evidence of bias in the DEIS against this alternative, and it should be deleted.
5. [3-l]. The DEIS states that "Cache County is expected to have considerable growth, with population almost doubling by the year 2010 ... " What is the basis for this statement? No data on expect­ed population growth, or past trends, is presented in sufficient detail for analysis in the DEIS. Earlier growth predictions have been modified considerably in light of more recent data, generally lowering such predictions. Clearly, the intent of this statement is to support the traffic predictions of chapter 1. Without data, however, this statement is unsupported, and may be quite in error. CEQ Regulations require that data in support of predictions must be made available in the DEIS.
6. [3-16]. Population and Growth. Table 3-2 gives minimal data on past population in Cache and Rich counties. It also projects the estimated future population growth to the year 2010. No data is given in support of this table. What is the date of the data? Which entries are actual population figures, and which projections? In order to determine the validity of the predictions, past data for the years 1970-1990 must be given, as well as a description of the regression methodolgy used to make the projections. Without this, it is impossible to know if these numbers are valid. This problem has been discussed above with respect to predictions of traffic volume and the same caveats apply.
7. [4-4]. Benefit/Cost. The DEIS states that "Table 4-2 does not include values of environmental impacts or benefits." The cost-­benefit analysis therefore is completely invalid, since the major controversy with the project is its effects on the environment. Why are such costs, to the extent they can be estimated, not includ­ed? Such costs should include tourist doll ars spent because of the scenic attractions of Logan Canyon, dollars spent by fishermen, hikers, bikers and skiers to enjoy the values of the canyon, and dollars associated with water quality and wildlife habitat. To what extent will each of t hese be affected by each alternative? this is a critical part of any cost-benefit analysis, but it is totally ignored in the DEIS. As a result, this analysis is without value, and should be completely revised to take into account these impor­tant factors. Again, CEQ Regulations require that all relevant factors be considered in evaluation of environmental effects.
8. [4-26]. Botanical and Wildlife Resources. Botanical impacts. The DEIS indicates that the Standard Arterial Alternative, Rich County Alignment Alternatives, and the Modified Standard Alternative may constitute a significant threat to the endangered species Primula maguirei. In fact, a conflict of expert opinion exists on this effect, and, if it is indeed significant, these alternatives would have to be dropped, or modified. Thus, it is impossible to determine from the DEIS if these alternatives must be further considered. This constitutes a violation of the CEQ Regulations
referred to above, since all environmental effects must be specified and discussed for each alternative. This conflict should have been resolved before the DEIS was published, and it must be resolved before the EIS is completed if any of these alternatives are to be considered. Table 4-15 is in error for these alternatives, since it indicates there are no Threatened or Endangered Species in any alternative.
9. [4-36]. Conservationists Alternative. The DEIS states that impacts [on wildlife] " ... would be similar to the Spot Improvements Alternative, but would be less extensive." This is grossly mislead­ing, as a comparison of the maps for the Middle Canyon for the two alternatives, and Tables 2-2 and 2-3 shows. The impacts of the Conservationists Alternative are far less than those of the Spot Alternative. This statement is further evidence of the bias of the DEIS against the Conservationists Alternative.
10. [4-42). Mitigation. Both tables 4-9 and 4-10 indicate that the VQR of the Composite and Conservationists Alternatives, with and without mitigation, are almost identical. This is indeed difficult to believe, considering the great difference in the amount of land disturbed in the two alternatives [see maps and tables for each]. A justification of this conclusion, in quantitative terms must be furnished; otherwise, it stretches the credulity of any rational person.
11. [4-53). Land Use. Compliance with Local Land Use Plans, Wasatch-Cache National Forest and Resources Management Plan-Manage­ment
Directives for Logan Canyon. The DEIS indicates that in all alternatives, except No Action, the visual management directives of the Forest Plan would be violated, and in all Alternatives, except No Action and Conservationists Alternatives, maintenance of stream habitat directives would be violated. The Conservationists Alternative fails to comply with the visual VQR of retention in only one, relatively minor, instance, while the other alternatives fail in this respect in varying degrees, with the Standard Arterial be­ing the most egregious. In fact, this alternative would not comply for the majority of the Middle Canyon, and much of the Upper ranyon [Beaver Creek, e.g.). The Composite Alternative fails, also to meet the standard, particularly in the Middle Canyon and in the Beaver Creek area. The OEIS assumes that, with the adoption of any of these non-complying alternatives, the Forest Plan will be amended , changing the VQR rating from retention to modification, or partial retention, and dropping the stream habitat maintenance requirement in affected areas. In reading the OEIS, one gets the impression that these changes would be relatively simple, and would be almost automatic. Such is far from the case. The Forest Plan was developed only after many years of work by the Forest Service and was subjected to extensive and critical public review. It should be pointed out that the Forest Plan is one of the few Forest plans in Utah, or in the nation, that was not appealed by environ­mental organizations. The reason for this is that this plan was
viewed as being perhaps the best in the state, and this judgement was based, in part, on the protection it provided for Logan Canyon. The VQR ratings of retention and the stream habitat maintenance requirements are a critical part of this protection, and they will not be changed without a long process of appeal and possible legal action. The Forest Plan states "The road will not be raised to a higher standard than existing." Environmental organizations and­conservationists regard this as binding on the Forest Service, and only compelling reasons, certainly of far more importance than any cited in the DEIS, would be required to change this. In fact, any significant change for purposes of raising the road to a "higher standard" will be considered as a profound breach of faith by the Forest Service that will certainly greatly reduce its credibility. Furthermore, the large number of areas requiring changes in the VQR, and the destruction of riparian zones [stream maintenance] in all alternatives except the Concervationists and No Action, will require not an amendment [or amendments] - but rather a Plan Revision, a
far more lengthy and difficult process than an amendment. The DEIS treats this matter far too lightly, and does not discuss what the process of amendment or revision entails. Much time and resources will be e xpended, both by the Forest Service and environmental organizations, in order to change [or prevent change] of the Plan to meet any of the Alternatives except No Action or the Conservation­ists.
In Summary, the DEIS provides insufficient justification for con­struction, lacks necessary detail, is biased towards the Composite Alternative, puts off required discussion of effects and mitigation to a future "final design plan" in violation of CEQ REgulations and does not provide the basis for a rational decision concerning alternatives. Considering the cost [approximately $l,000,000], the great amount of time spent by everyone, and the fact that most of the serious problems discussed here were discussed repeatedly at the ID Team meetings, the DEIS is, to put it charitably, a disappointment. More importantly, it does not meet the primary criterion of an EIS, which is defined in the CEQ regulations governing the preparation of environmental impact statements: "It shall provide full and fair discussion of significant environmental im­pacts
and shall inform the decision-makers and the public of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of the human environment." [§1502.1J.
Finally, as provided for in the CEQ Regulations [§1503.3] [a]], I wish to express my opinion of the merits of the alternatives. Only the Conservationists Alternative meets the needs of the canyon: reconstruction of the bridges, and some improvement in traffic flow by the use of pullouts and passing lanes in acceptable loca­tions, and the maintenance of highway which fits into Logan Canyon with minimal ecological disturbance and maximum safety. I strongly endorse this alternative.
Jack T. Spence